The World Shipping Council (WSC) is calling for governments and the International Maritime Organization (IMO) to address a regulatory gap that it says is creating a serious safety risk in containerised cargo transport.
Under the current rules, small lithium-ion batteries can qualify for an exemption when shipped individually, allowing them to move without being declared as dangerous goods. The concern is that the same exemption can effectively cover containers carrying thousands of batteries.
Individual batteries must meet strict requirements, including passing prescribed tests, protection against short circuits, robust packaging and the use of the lithium battery mark. However, the WSC says these safeguards do not provide sufficient visibility when large quantities are consolidated into a single container.
“Right now, a container can be packed with thousands of lithium batteries and still travel without being declared as dangerous goods,” said WSC president and CEO Joe Kramek. He argued that Special Provision 188 (SP188) was designed to simplify the transport of individual devices containing small batteries, rather than allow entire container loads to remain unidentified.
Industry backs proposal for stronger controls
In July a proposal to close this gap was submitted to the IMO Sub-Committee on Carriage of Cargoes and Containers. The proposal is put forward by Germany, Marshall Islands, Netherlands, Singapore and Thailand and is backed by industry organizations including BIMCO, the International Chamber of Shipping (ICS), ICHCA, the International Transport Workers’ Federation (ITF), the International Union of Marine Insurance (IUMI) and the WSC.
The proposal suggests a mechanism to visualize the presence of these goods inside containers. It leverages an existing provision of the International Maritime Dangerous Goods (IMDG) Code, called Special Provision 963 (SP963).
SP963 establishes maximum weight limits on containers transporting dangerous goods at which thresholds hazard communications are triggered . The Dangerous Goods List also includes stowage, handling and segregation requirements specific to the maritime mode.
The proposed approach would express the SP963 threshold in terms of gross mass at a level of 100 kg gross mass or more.
This threshold is similar to the SP188 maximum gross-mass limit for package-level at 30 kg, the proposal notes. The authors argue that compliance with a gross mass measurement would be easier, while a watt-hour (Wh) threshold could be more precise.
X-Press Godavari fire highlights the risk
The WSC pointed to the 2020 fire aboard the 920-TEU X-Press Godavari as an example of what can happen when large quantities of lithium-ion batteries are carried under the existing exemption.
The vessel was sailing from Malaysia to India in temperatures ranging from 27°C to 30°C. In the early morning of 28 September, the captain and chief officer noticed that a loaded container on deck was smoking.
The crew initially had no information about what the container contained. Despite applying boundary cooling, they found that the smoke was becoming increasingly intense.
The fire continued for around 42 hours, including after the container had been discharged from the vessel and firefighters attempted to bring the blaze under control.
A subsequent investigation found that the container held more than 1,000 cartons of torch batteries and lithium-ion batteries. The shipper had supplied a “Certificate for Safe Transport”, including packaging information and sample testing intended to demonstrate compliance with SP188.
An investigation report into the incident found that more than 7,000 kg of lithium-ion batteries had been packed inside the container. It concluded that even if only one battery had caught fire, there was nothing that could have prevented the fire from spreading throughout the container and consuming the remaining cargo.
For the first hour and a half after the fire began, the crew did not know what was inside the container. They only received that information after the shipper responded to email enquiries.
Significantly, the investigation also found that the shipper had complied with all the safety requirements established by the applicable regulations.
Nevertheless, SP188 had allowed the lithium-ion batteries to be shipped without being declared. The shipper had followed the special provision’s requirements and had also obtained a Certificate for Safe Transport from a certification company.
WSC seeks greater visibility for battery cargo
The WSC argues that the existing regulatory framework is therefore failing to adequately protect shippers, cargo, the environment and crew members.
As battery shipments continue to expand, Kramek said the industry needs rules that make these cargoes visible before an incident occurs and enable operators to manage the associated risks more effectively.
“As battery shipments continue to grow, we need a better solution that makes these cargoes visible and allows the risks to be properly managed,” he said.
